Conflict Minerals

Please inform us, before delivery, if the products/materials which you are delivering to us contain conflict minerals. If this is the case, please tell us which conflict minerals in particular are involved and what products are affected.

Otherwise, we will assume that there are no conflict minerals in your products/materials.

The mandatory obtaining of certificates of origin for so-called conflict materials is being increasingly discussed by the EU. The European Commission has undertaken a consultation under the direction of Commissioner Karel De Gucht from the Directorate-General for Trade. It is generally believed that this obligation will be placed on European industrial companies in the near future - although as of July 2013 the detailed organization was still open. The Dodd-Frank Act (Paragraph 1502) on conflict materials serves as a blueprint for this EU initiative. The purpose of this law is to prohibit the use of so-called conflict minerals which are an essential financial resource for rebels in the East Africa.


Under the Dodd-Frank Act (Paragraph 1502), listed US companies are currently obliged to disclose the origin of certain raw materials in their products (and means of production) and to document these in a certain way. These so-called "conflict materials" include, in particular, tin, tantalum, tungsten and gold, which are mined in the Congo and in the East African Great Lakes region. The scope of this disclosure requirement under the Dodd-Frank Act covers listed companies in the United States. Indirectly, it affects current suppliers to US companies, in particular companies from the fields of electrical engineering and electronics, aerospace, automotive, jewellery, medical and industrial products.

Under the Dodd-Frank Act, listed US companies must disclose in their annual report whether their products or means of production contain tin, tantalum, tungsten and/or gold from the region which includes the Democratic Republic of the Congo (DRC), the Central African Republic, South Sudan, Zambia, Angola, the Democratic Republic of the Congo, Tanzania, Burundi, Rwanda and Uganda. In order to check the truth of their statement, a certificate of origin must also be submitted if no conflict materials are included in the products. The report needed to be filed with the SEC for the first time on 31 March 2014, for the calendar year 2013.


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